Airborne 08.18.17

Association Does Not Support Forms' Continued Usage

In a letter to the FAA, the
Aircraft Electronics Association (AEA), said while it does
support the continued use of FAA Form 337, it is important for the
Agency to accurately account for the public burden associated with
the use of this form in its request to the Office of Management and
Budget. The AEA represents more than 1,300 aviation businesses
including repair stations that specialize in maintenance, repair
and installation of avionics and electronic systems in general
aviation aircraft, as well as instrument facilities, manufacturers
of avionics equipment, instrument manufacturers, airframe
manufacturers, test equipment manufacturers, major distributors,
and educational institutions,

FAA Form 337 is used as a simple record for major alterations
and major repairs (as suggested in the public notice); however, the
form also is used for the FAA approval of repair and alteration
data (field approval); submitting an Instruction for Continued
Airworthiness (ICA) for acceptance by the local FAA Flight
Standards District Office (FSDO); and as a cover sheet for the FAA
approval of Flight Manual Supplements (FMS).

In the letter, the Aircraft Electronics Association says it
does not support the FAA's request for continuance of information
collection as proposed in OMB Control Number: 2120-0020. While the
Association It is critically important for FAA Headquarters
to understand and take responsibility for the public burden of this
form, including the "unauthorized" uses of this form and the
inappropriate local mandates for data, which is not supported
through this OMB request. Finally, the FAA must not have
conflicting public guidance in AC 43.9-1 and FAA employee guidance
in FAA Order 8900.1.

In responding to the FAA's specific questions, the AEA said that
it is important for the Agency to collect information in its
efforts to manage and document the airworthiness of aircraft and
components. However, the AEA says the Agency has significantly
underestimated the public burden. Unfortunately, the Agency only
accounted for the recording of a major alteration that is
accomplished via a Supplemental Type Certificate (STC). The
association says the use of FAA Form 337 has far exceeded the
simple recording of an STC. In recent years the data collection
burden has grown unbound with little or no control of the use of
the form by FAA Headquarters.

"While the use of FAA Form 337 for a "field approval" of
alteration and/or repair data clearly is accounted for in FAA
Advisory Circular 43.9-1F, the additional burden of using FAA Form
337 for ICA approval is contained in the internal FAA policy, FAA
Order 8900.1," the letter states. "In this order, there is a
prohibition of issuing a field approval to the public without the
accompanying ICA. While FAA Headquarters has not officially
endorsed the use of FAA Form 337 for FMS approval, it is common
practice in the FSDO.

Each of these non-accounted for uses of FAA Form 337 easily can add
an additional eight hours of burden for each of the three approvals
- in essence, adding as much as 24 additional hours of
burden.

The reason the burden for these additional uses tends to be so high
is because the approval is given at the local FAA field inspector
level and the FAA does not have clear, concise guidance or policy
to guide the pubic and/or limit FAA employees from adding their
personal preferences to the data collection requirements.

The AEA told the FAA it "must harmonize
its public advisory circular with its internal FAA inspector
guidance. The fact that FAA Order 8900.1 contains requirements not
contained in AC 43.9-1F is a major deterrent to a simple,
cost-effective use of FAA Form 337.

"In addition, the "unofficial" use of FAA Form 337 for Flight
Manual Supplement approval is not acceptable. AC 23-8 and AC 25-7
provide clear instructions for submitting FMS revisions to the FAA
for approval. The instructions in these advisory circulars do not
include the use of FAA Form 337 as a tracking document."

And finally, the association said the FAA must take responsibility
for the inconsistent use of this form and the "unofficial" uses of
this form as mandated by the local FSDO offices. AC 43.9-1 must be
updated to provide clear instructions on each application of FAA
Form 337. In addition, FAA Headquarters must hold its field
employees accountable to the limits of the data collection as
provided in AC 43.9-1.